Court of Appeals Digest: May 4, 2026

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Civil Nonprecedential

Civil Commitment

SDP; Sufficiency of the Evidence

Appellant challenged his indeterminate civil commitment as a sexually dangerous person (SDP), arguing that the District Court erred by admitting police reports describing uncharged sexual assaults without live testimony and that the evidence did not clearly and convincingly establish the statutory commitment criteria. The Court of Appeals held that the District Court did not abuse its discretion in admitting the reports, concluding that commitment proceedings permit consideration of relevant and reliable evidence, including hearsay, and that the reports—generated close in time to the alleged incidents and containing firsthand accounts—were properly considered and weighed against other evidence. The court further held that admission of the reports did not violate due process because there is no confrontation right in civil commitment proceedings and respondent had an opportunity to rebut the allegations. On the merits, the court determined that clear and convincing evidence supported commitment, emphasizing appellant’s pattern of harmful sexual conduct involving multiple victims over time, expert diagnoses establishing a disorder impairing his ability to control sexual behavior, and evidence— including actuarial assessments—showing he was highly likely to reoffend. Affirmed.

A25-1999 In re Civ. Commitment of Tillman (Chisago County)

Contracts

Indemnification

Appellant, amusement park owner, challenged a judgment requiring it to indemnify respondent, amusement park builder, for settlement and defense costs arising from a personal-injury action involving an amusement ride, arguing that the contract lacked specific language covering such costs, that a Pierringer settlement barred recovery, and that common-law indemnity principles precluded liability. The Court of Appeals held that the indemnification clause, when liberally construed, required appellant to indemnify respondent for losses caused by appellant’s negligent operation of the ride, where the jury found respondent free of fault. The court further held that the contract’s broad definition of “losses” encompassed both attorney fees and the amount paid in settlement, rejecting appellant’s attempt to narrowly construe the term. The court also concluded that the Pierringer agreement did not extinguish appellant’s contractual indemnification obligation because the parties’ preexisting indemnity relationship operated independently of contribution principles and could not be prejudiced by the settlement. Finally, the court rejected appellant’s reliance on common-law indemnity doctrines, determining that contractual indemnification governed. Affirmed

A25-1017 Karre v. City of Duluth (St. Louis County)

Domestic Relations

Child Custody; Domestic Abuse

Appellant-mother challenged the District Court’s award of joint legal custody following a custody-modification proceeding, arguing that the court failed to properly apply the statutory presumption against joint custody when domestic abuse has occurred and that its findings regarding parental cooperation were unsupported. The Court of Appeals held that the District Court’s findings were insufficient because, although it concluded that the domestic-abuse best-interest factor favored mother, it failed to make an express finding that domestic abuse occurred or to provide the detailed findings required to address the statutory presumption against joint custody. The court further determined that the District Court did not adequately analyze the nature and context of the alleged abuse or its implications for the children’s safety and well-being, as required by statute. The court also concluded that the District Court failed to reconcile findings of high parental conflict with its conclusion that the parties could cooperate in child-rearing decisions. Reversed and remanded.

A25-1208 Wills v. Wills (Otter Tail County)

Domestic Relations

Child Custody; School

Pro se appellant-mother challenged post-dissolution determinations regarding the children’s schooling and denial of a name-change request, along with multiple procedural and ancillary rulings. The Court of Appeals held that the District Court did not abuse its discretion in ordering traditional schooling rather than homeschooling, concluding that the record supported findings that the children’s educational needs were better met through available school-based resources and that homeschooling had not provided comparable support or progress. The court further held that the District Court properly denied the requested name change, determining that the court reasonably applied the best-interests standard and Saxton factors, permissibly declined to enforce a prior informal stipulation, and reasonably weighed the children’s age, preferences, and cultural considerations. The court rejected additional due-process and related claims as inadequately briefed or unsupported. Finally, the court declined to consider challenges to transcript accuracy, parenting-time restrictions, and a later child-support order. Affirmed.

A25-1172 Diomande v. Diomande (Wright County)

Domestic Protection

Child Protection; Custody Transfer

Appellant mother challenged the transfer of permanent legal and physical custody of her child to a relative caregiver, arguing that the county failed to make reasonable reunification efforts—particularly regarding housing assistance and sobriety support. The Court of Appeals held that the District Court did not abuse its discretion in determining that reasonable efforts were made. The court concluded that mother failed to preserve her specific appellate arguments but, in any event, the record showed that the county provided case-management services, referrals, and assistance tailored to mother’s needs, including housing resources and substance-use testing options. The court emphasized that mother’s lack of cooperation—such as refusing to disclose her residence, failing to engage with housing assistance, missing or compromising drug tests, and minimizing substance-use concerns—supported the determination that reunification efforts were reasonable. Affirmed.

A25-1917 In re Welfare of Child(ren) of D.M.D. (Hennepin County)

Domestic Relations

Dissolution; Child Custody

Following marital-dissolution proceedings, appellant-mother challenged a dissolution judgment awarding father sole legal and physical custody, limiting her parenting time, valuing marital property, and denying relief on other financial and procedural issues. Noting mother’s absence, lack of cooperation, and unwillingness to support father’s relationship with the children were supported by the record and entitled to deference, the Court of Appeals held that the District Court did not abuse its discretion in awarding sole custody. The court further held that the District Court properly departed from the statutory presumption of at least 25% parenting time based on findings that mother relocated to another country, failed to exercise available parenting time, and that increased travel would disrupt the children. The court also affirmed the valuation of the parties’ “tiny house.” Affirmed.

A25-0799 Haines v. Haines (Carlton County)

Domestic Relations

Dissolution; Marital Property

Appellant-husband challenged the District Court’s division of marital property, award of spousal maintenance, and calculation of child support following dissolution. The Court of Appeals held that the District Court did not abuse its discretion in valuing and dividing marital assets and debts, emphasizing that the absence of a trial transcript required deference to the District Court’s factual findings and that the record supported the equalizer payment and allocation of real property, vehicles, and accounts. The court further held that the spousal-maintenance award was within the District Court’s discretion, concluding that the findings supported wife’s need and husband’s ability to pay, and that the amount and duration were justified under the statutory factors. However, the court determined that remand was required on child support because the District Court failed to explain how it calculated the number of parenting-time overnights used in the parenting-expense adjustment, preventing meaningful appellate review. Affirmed in part and remanded.

A25-1295 Aravalli v. Aravalli (Hennepin County)

Domestic Relations

Parenting Time; Special Masters

Appellant-father challenged multiple post-judgment orders arising from ongoing post-judgment dissolution proceedings, including the District Court’s adoption of a special master’s decisions, denial of motions for temporary custody and medical directives, and refusal to amend a temporary school-choice order. The Court of Appeals held that the District Court did not abuse its discretion in adopting the special master’s determinations regarding parenting time and communication protocols, concluding that those matters were within the scope of the special master’s authority and supported by the record. The court further held that father forfeited certain arguments and that the temporary school-choice order did not constitute a modification of legal custody and therefore did not violate statutory restrictions. Additionally, the District Court acted within its discretion in referring school-related disputes to the special master. Finally, the court determined that father’s request for emergency relief regarding school enrollment was moot and otherwise unsupported. Affirmed.

A25-0889, A25-1621 Marinac v. Marinac (St. Louis County)

Driver’s License Revocation

Alcohol Testing

Pro se appellant challenged the revocation of her driving privileges, arguing that the traffic stop lacked reasonable articulable suspicion, that the warrant for a blood or urine sample was unsupported by probable cause, and that the District Court improperly excluded evidence. The Court of Appeals held that the traffic stop was lawful, concluding that the deputy’s observation of a traffic violation—crossing a lane line—provided an objective basis for the stop regardless of the officer’s subjective beliefs. The court further held that the warrant was supported by probable cause under the totality of the circumstances, including observed indicia of impairment, field-sobriety-test results, and the discovery of suspected methamphetamine and paraphernalia, and that appellant failed to establish any material misrepresentation or omission. Affirmed.

A25-1229 Edwards v. Comm’r of Pub. Safety (Wright County)

Human Services

Professional Disqualification

Relator applicant for employment in licensed residential mental-health programs challenged a decision by the Department of Human Services denying his request to set aside a statutory disqualification based on a misdemeanor domestic-assault conviction. The Court of Appeals held that the commissioner’s decision was supported by substantial evidence and was not arbitrary. The court concluded that the commissioner properly evaluated all nine statutory risk-of-harm factors, including the severity of the assault, the vulnerability of the populations served, the similarity between the victim and those populations, and relator’s limited insight into his conduct. The court emphasized that relator’s minimization of the offense and failure to accept responsibility supported the determination that he continued to pose a risk of harm, notwithstanding evidence of rehabilitation efforts. Affirmed.

A25-1660 Spry v. Dep’t of Human Servs. (Dep’t of Human Servs.)

Landlord & Tenant

Eviction

Appellant-tenant challenged summary judgment in favor of landlord in an eviction action for holding over after lease termination, arguing that the termination was retaliatory and discriminatory based on his status as a medical-cannabis patient and his request to smoke medical cannabis in his apartment. The Court of Appeals held that appellant was not entitled to a retaliation defense because Minnesota law does not create a statutory right to smoke medical cannabis in multifamily housing. Interpreting Minn. Stat. §§ 342.56 and 504B.171 together, the court concluded that while the former does not prohibit smoking medical cannabis, the latter expressly allows landlords to prohibit smoking cannabinoid products, including medical forms, on leased premises. The court further held that appellant was not entitled to a discrimination defense because the lease was terminated based on his violation of a no-smoking policy, not solely his status as a medical-cannabis patient. Finally, the court rejected appellant’s argument that a civil fine was the proper remedy, concluding that eviction was authorized under the applicable landlord-tenant statutes. Affirmed.

A25-1279 At Home Apts., L.L.C. v. Berscheid (Stearns County)

Medical Malpractice

Expert Affidavits

Appellant-patient sued respondent-hospital for medical malpractice, claiming nursing staff broke her spine while she was recovering from surgery and rendered her paraplegic. The District Court dismissed the complaint for failure to meet the expert-affidavit requirements in Minn. Stat. § 145.682. Appellant argued that expert testimony was unnecessary because her claim fell within common knowledge and, alternatively, that her expert affidavits were sufficient. The Court of Appeals held that expert testimony was required because the alleged injury—paralysis following spinal surgeries and postoperative care—involved complex medical issues beyond the understanding of laypersons. The court further held that appellant’s expert submissions were insufficient to establish a prima facie case, concluding that her qualified expert failed to adequately outline the chain of causation connecting alleged negligent repositioning and delayed treatment to her injuries. The court emphasized that conclusory statements regarding causation, without specific factual explanation of how and why the alleged conduct caused the injury, did not satisfy the statutory requirements. Affirmed.

A25-1293 Forbort v. St. Mary’s Med. Ctr. (St. Louis County)

Municipalities

Notice of Claims

Appellant passenger injured at an airport challenged summary judgment in favor of a municipal airport operator, which had dismissed her personal-injury claim for failure to comply with the notice requirements of Minn. Stat. § 466.05. The Court of Appeals held that the passenger’s initial notice letter to the airport operator did not substantially comply with the statute because it failed to provide sufficient detail about the circumstances of the injury to allow investigation. However, the court further held that dismissal was improper because a genuine issue of material fact existed as to whether the deficient and/or untimely notice prejudiced the airport operator. The court emphasized that lack of notice is not jurisdictional and that the municipality bears the burden of proving prejudice, which was not established on the summary-judgment record. Reversed and remanded.

A25-1393 Christensen v. Metropolitan Airports Commission (Hennepin County)

Torts

Assumption of the Risk

Appellant homeowner challenged summary judgment dismissing her negligence, nuisance, and trespass claims against a golf-course operator for repeated property damage caused by errant golf balls, as well as the denial of her motion to amend to add punitive damages. The Court of Appeals held that summary judgment was improper because genuine issues of material fact existed regarding whether the frequency of golf balls striking appellant’s property constituted an “abnormal” hazard beyond the “usual and normal” risks she assumed under a recorded easement and covenant. The court concluded that appellant’s expert report and record evidence created fact issues as to whether the course’s design and maintenance—particularly the configuration of a dogleg hole—unreasonably increased the risk of harm. The court further held that these factual disputes precluded dismissal of appellant’s negligence, nuisance, and trespass claims, including whether respondent’s mitigation efforts were adequate and whether its conduct was wrongful. Finally, because the District Court denied appellant’s motion to add punitive damages solely based on its grant of summary judgment, the court reversed that denial and remanded for consideration on the merits. Reversed and remanded.

A25-1260 Neegard v. Valley Golf Association (Polk County)

Unemployment Benefits

Severance Pay

Relator employee challenged a determination that she was ineligible for unemployment benefits following her separation from employment with a telecommunications employer, arguing that the ineligibility period should not begin until she accepted a severance agreement and received payment. The Court of Appeals held that the unemployment-law judge correctly applied Minn. Stat. § 268.085, concluding that severance pay renders an applicant ineligible for benefits during the period immediately following separation or when the applicant becomes aware that severance will be paid, whichever is later. The court determined that the employee knew at the time of separation that she would receive severance pay, and therefore the ineligibility period began immediately after her last day of employment, regardless of when she later accepted the agreement or received the lump-sum payment. Affirmed.

A25-1509 Crossfield v. AT&T Servs. Inc. (Dep’t of Emp’t & Econ. Dev.)

Civil Order Opinions

Civil Commitment

Right to Counsel

Appellant challenged the denial of his motion for relief from judgment under Minn. R. Civ. P. 60.02, arguing that his original civil commitment was invalid because he was not afforded an opportunity to waive counsel at the initial commitment proceeding and that the District Court erred by denying relief without a hearing and declining to stay proceedings. The Court of Appeals held that the District Court did not abuse its discretion in denying the motion. The court concluded that appellant failed to demonstrate any change in circumstances warranting relief, rejecting his reliance on recent caselaw addressing waiver of counsel in a different procedural context. The court further held that appellant forfeited his structural-error argument by inadequate briefing and failed to establish any legal basis for a right to self-representation at the initial commitment stage. The court also determined that the District Court acted within its discretion in denying the motion without an evidentiary hearing and that the request for a stay was moot. Affirmed.

A25-1592 In re Civ. Commitment of Hollie (Hennepin County)

Health Care

Warranties

Appellant dental patient challenged dismissal of his breach-of-contract and good-faith claims against a dental practice and its providers arising from a failed dental-bridge procedure and refusal to refund payment. The Court of Appeals held that the District Court properly dismissed the complaint for failure to state a claim. The court concluded that appellant forfeited his implied-warranty-of-merchantability argument by failing to raise it before the District Court and could not assert it for the first time on appeal. The court further held that, in any event, the transaction was predominantly for professional services rather than goods, undermining the applicability of warranty principles. Finally, the court rejected appellant’s argument regarding expert affidavits, determining that any discussion of malpractice requirements did not affect dismissal of the contract-based claims, which independently failed as pleaded. Affirmed.

A25-1665 Gabbert v. Marshall Dental Excellence (Lyon County)

Orders for Protection

Domestic Abuse

Appellant father challenged the issuance of an order for protection (OFP) obtained by mother on behalf of herself and the parties’ child, arguing that the evidence was not credible and did not support a finding of domestic abuse. The Court of Appeals held that the District Court did not abuse its discretion in granting the OFP. The court concluded that the District Court’s findings—that father followed mother to her workplace and placed her in reasonable fear of physical harm—were supported by credited testimony. The court further emphasized that father failed to provide a transcript of the evidentiary hearing, limiting appellate review and precluding challenges to the District Court’s credibility determinations. Affirmed.

A25-1366 Warns-Ledesma v. Mayfield (Ramsey County)

Criminal Nonprecedential

Controlled Substance Crimes

Sufficiency of the Evidence

Defendant challenged his conviction of first-degree controlled-substance possession and the denial of a downward dispositional departure. The Court of Appeals held that sufficient circumstantial evidence supported the conviction, concluding that the circumstances proved— including defendant’s high-speed flight from police, the timing and location of the discovery of a bag of methamphetamine along the pursuit route, and the condition of the drugs—supported a reasonable inference that defendant constructively possessed the drugs and excluded any rational hypothesis other than guilt. The court further held that the District Court did not abuse its discretion in imposing the presumptive sentence and denying a departure. Affirmed.

A25-1046 State v. Josie (Mille Lacs County)

False Emergency Call

Sufficiency of the Evidence

Defendant challenged her conviction for making a call for emergency police service knowing that no emergency existed, arguing that the state failed to prove she requested emergency service and that she knew no emergency existed. The Court of Appeals concluded that defendant’s 911 calls—demanding that officers “stand down” and leave her door—constituted requests for emergency police assistance under the statute. The court further held that the surrounding circumstances, including defendant’s complaints about neighbors, her repeated demands for police to leave, and the officer’s observation that no emergency was occurring, supported the inference that defendant knew no emergency existed. Affirmed.

A25-0774 State v. Gills (Olmsted County)

Plea Withdrawal

Intelligent

Petitioner sought to withdraw his guilty plea to first-degree criminal sexual conduct, arguing that the plea agreement included a 120-month sentencing cap or, alternatively, that ambiguity surrounding the agreement rendered his plea unintelligent. The Court of Appeals held that the plea was not constitutionally valid because it was unintelligent. The court concluded that the plea petition expressly indicated that the state would cap the sentence at 120 months, while other statements in the record suggested a “straight plea” with no sentencing agreement, creating material ambiguity regarding the direct consequences of the plea. Under the totality of the circumstances, the court determined that petitioner reasonably understood his sentence would be capped, and the lack of clarity prevented a knowing and intelligent choice among alternatives. Because this constituted a manifest injustice, the District Court abused its discretion in denying postconviction relief. Reversed and remanded.

A25-1512 Peralta Gutierrez v. State (Hennepin County)

Probation Revocation

Need for Confinement

Defendant challenged the revocation of his probation and execution of a previously stayed sentence, arguing that the District Court failed to make sufficient findings on the need for confinement. The Court of Appeals held that the District Court made adequate findings that confinement was warranted because not revoking probation would unduly depreciate the seriousness of the violations. The court concluded that the District Court properly considered defendant’s repeated drug use despite prior opportunities for treatment and intermediate sanctions, his failure to take advantage of a dispositional departure, and his broader criminal history demonstrating an inability to avoid antisocial behavior. The court further determined that the District Court thoughtfully weighed the competing considerations and did not act reflexively in revoking probation. Affirmed.

A25-1350 State v. Udstuen (Le Sueur County)

Sentencing

Downward Departures

The state appealed a downward dispositional departure granted to defendant following his conviction for financial transaction card fraud, arguing that the District Court abused its discretion in staying execution of the presumptive prison sentence. The Court of Appeals held that the departure was not supported by substantial and compelling circumstances. The court concluded that the District Court improperly relied on an offense-related factor—viewing the offense as less serious—to justify a dispositional departure, which must instead be based on offender-specific characteristics. The court further determined that the record did not support a finding that defendant was particularly amenable to probation, emphasizing his extensive criminal history, continued criminal conduct while on supervision, lack of meaningful engagement in chemical-dependency treatment, equivocal expressions of remorse, and questionable family support. Reversed and remanded.

A25-2117 State v. Fenske (Carver County)

Warrantless Searches

Automobile Exception

In this direct appeal from the judgment of conviction for unlawful firearm possession, defendant challenged the denial of his motion to suppress evidence discovered during a warrantless search of his vehicle following a traffic stop and arrest, arguing that the search was not justified under any exception to the warrant requirement. The Court of Appeals held that the search was lawful under the automobile exception, concluding that defendant’s possession of an open, unsealed bag of marijuana while inside the vehicle violated Minnesota’s open-package statute and provided probable cause to believe additional evidence of such violations would be found in the vehicle. Affirmed.

A25-0886 State v. Roberson (Hennepin County)

Criminal Order Opinions

Habeas Corpus

Evidentiary Hearing

Petitioner challenged the summary denial of his petition for a writ of habeas corpus and request for an evidentiary hearing, asserting multiple constitutional and procedural defects in his underlying murder conviction. The Court of Appeals held that the District Court properly denied the petition without a hearing. Because petitioner’s claims either were or could have been raised on direct appeal or in prior postconviction proceedings, the petition constituted an impermissible collateral attack on a valid conviction. The court further held that petitioner failed to allege specific factual disputes warranting an evidentiary hearing and instead raised only legal arguments and conclusory assertions. Affirmed.

A25-1532 Burdunice v. Bolin (Washington County)

Sentencing

Presentence Investigations

Petitioner challenged the denial of his motion to correct or modify his sentence, arguing that his sentence was unlawful because he was not provided a presentence investigation (PSI) report and that the District Court erred by construing his motion as a postconviction petition. The Court of Appeals held that petitioner was not entitled to relief because the record showed that defense counsel received the PSI before sentencing, satisfying statutory requirements, and petitioner later chose to proceed pro se after that disclosure. The court further held that petitioner failed to demonstrate that his sentence—within the presumptive guidelines range—was unauthorized by law. Because petitioner’s underlying claim lacked merit, the court declined to decide whether the District Court erred in treating the motion as a postconviction petition. Affirmed.

A25-1495 El v. State (Ramsey County)